PME INVESTIMENTOS – SOCIEDADE DE INVESTIMENTO, S.A.
CHAPTER I

GENERAL PROVISIONS

Article 1

(Nature and scope)

1. This Code includes a set of ethic and professional conduct principles and rules of conduct that are required to be complied with  by PME INVESTIMENTOS – Sociedade de Investimento, S.A. (hereinafter, the Company) and all staff, internally and while acting on behalf of the Company before third parties, both on a permanent or occasional basis.

2. For the purposes of this Code, staff shall be deemed to be every person working at the Company or collaborating with it, regardless of the contractual relationship and hierarchic position, including members of corporate bodies, directors, managers and officers, or any permanent or temporary employees, consultants and all those who, somehow, act on behalf of the Company or provide it a service on a permanent or occasional basis.

Article 2

(Ethical scope of the Company and general rules of conduct)

1. The Company, in its business, which will be pursued with respect for strict ethical, deontological, legality, social responsibility and sustainable development principles, undertakes to:

a) Support economic, social and environmental sustainability, in the decision-making process, searching for add-value, resources’ efficiency, environmental protection and optimisation of human capital;

b) Uphold organizational and operational procedures guided by high accurateness, competence and professionalism standards;

c) Preserve an irreproachable behaviour from an ethical standpoint, notably regarding the compliance with tax, labour and money laundering laws;

d) Promote, notably, in accordance with the applicable legal framework, the respect for equal treatment and opportunities for all staff members, current and potential;

e) Defend the moral integrity of staff members and condemn any form of moral or psychological coercion, and any behaviour offensive of the dignity of the human being or discriminating;

f) Encourage the improvement and personal and professional development of staff members, allowing the compromise between personal, family and professional life;

g) Endorse equal treatment and equal opportunities for all of its suppliers, customers, other holders of legitimate interests and, in general, entities having a connection with the Company, which shall act towards these fairly;

h) Maintain relationships with third parties with full respect for the principles and values ??contained in this Code.

2. Those acting on behalf of the Company must be, professionally, guided by the principles and values ??contained herein, including of professional conduct and personal integrity, and should additionally:

a) Ensure the enforcement and sharing, within the Company, of principles of truth, fairness, accurateness and transparency, thus strengthening the spirit and identity of the Company;

b) Perform their duties with professional and moral integrity, as well as personal integrity, truthfulness, complete impartiality, dedication, diligence and transparency;

c) Submit to the chain of command, when applicable, any query or doubt they may deem appropriate in relation to this Code, with the final clarification to be given by the Board.

CHAPTER II

CONDUCT RULES

Article 3

(Compliance with the law)

The Company and its staff shall, professionally, respect the applicable laws and regulations in force.

Article 4

(Interpersonal relationship and with third parties)

1. Staff members must have their professional relations based on mutual respect and treat others with courtesy, consideration and professionalism, helping to create a good work environment, particularly through mutual collaboration and cooperation.

2. No form of discrimination shall be permitted where contrary to the dignity of the human being, in particular, on grounds of nationality, race, age, sex, religion, disability, political or ideological affiliation or union membership, as well as any form of sexual harassment or abuse of power.

3. The Company and its staff, when dealing with third parties, must ensure equal treatment in all situations where there is no cause for legal and / or contractual right to proceed differently.

4. Staff members must also exhibit, in the performance of their duties, high levels of professionalism, respect, truthfulness and courtesy in dealing with all third parties with which the Company relates, acting to provide an efficient service, as well as an accurate and timely response to requests.

5. Information provided by the Company, through its staff members, the media or the general public, should be accurate, informative, true and timely, as well as respect the procedures and hierarchical instructions in place, and should in all cases be subject to prior authorization by the Company.

Article 5

(Relations with regulators and supervisory bodies and the public administration)

1. Company and staff members shall, promptly and in a timely manner, offer regulators, supervisors and other supervising entities their full collaboration, complying with requests, facilitating supervising actions and refraining from any behaviour which may obstruct the powers of the aforementioned authorities.

2. When interacting with public administration, staff members shall proceed with courtesy and diligence, asking their chain of command, where applicable, for guidance as they may deem necessary, as well as clarifying any queries.

Article 6

(Funds’ Management, relationship with participants and entities with arrangements with the Funds)

1. The Company, while acting in its capacity of Funds’ manager, also undertakes to:

a) Carry out the activities and operations required for the good administration of the Funds under management, in accordance with high standards of professional diligence and skill;

b) Select assets to be included in the portfolio of Funds under management, according to the relevant investment policy as per the funds’ management rules and regulations, and perform all acts necessary for the correct execution of this strategy;

c) Perform its business towards the protection of the lawful interests of the participants of the Funds under management;

d) Favour the best interests of the Funds under management and respective participants over its own interests, refraining from intervening in business that may cause conflicts of interest with the participants;

e) Grant equal treatment to funds under management and to the participants, as well as to the entities holding arrangements with the Funds, refraining from making distinctions between those, unless there are grounds for a differential treatment.

2. The Company, while acting, as well as in the operational and accounting records, shall ensure a strict and clear distinction between the assets belonging to its own assets and the assets relating to the Funds under management.

Article 7

(Disclosure of information)

1. The Company shall provide all entities with which it relates, including the participants of the Funds under management, complete, true, timely, clear, objective and lawful information on the matters subject to the discretion of those entities and / or resolution of aforementioned participants, in order to allow them to form a reasoned opinion on those matters.

2. The Company, with adequate regularity, namely, the nature of the Funds under management, or immediately when the circumstances so demand, shall provide to the participants of the Funds information, pursuant to the provision set forth under number 1 above, regarding operations and investments made, the values ??of assets and liabilities of the Funds and, also, the fees and other expenses charged by the Company or paid by this latter to other entities.

3. Annually, the Company will inform its shareholders, and the general public, on the form its mission was pursued, the level of achievement of its objectives, and the way it fulfilled its social responsibility and sustainable development policy.

Article 8

(Confidentiality and professional secrecy)

1. Staff members must maintain full confidentiality with regards to all facts and information about the Company and third parties, including the Funds under management and its participants, that comes to their knowledge in the exercise of, or because of their duties, and must also use the utmost prudence and discretion to avoid disclosure of facts that could harm the Company and which are not intended for disclosure.

2. Staff members may only use and disclose the facts and information referred to in the preceding provision in the interest of, and when expressly authorized by, the Company, and may not use or distribute, directly or indirectly, the facts and information for their own personnel or third parties’ advantage.

3. The duty of confidentiality and professional secrecy set out in this Article shall remain fully applicable and in force even when the recipients are no longer staff members of the Company and no longer perform their duties in, or render services to, the Company.

Article 9

(Conflicts of interest)

1. Staff members, in the exercise of their duties, are prevented from participating in the decision-making process that, directly or indirectly, relates to entities where they collaborate or have collaborated, or with people who are family or kin, affinity or in any other way related, and must notify the Company of the existence of any such links, in order to allow a balanced and equitable solution that ensures impartial, independent, objective and transparent performance by the Company.

2. The resolution of conflicts of interest shall scrupulously respect the legal, regulatory and contractual provisions applicable.

CHAPTER III

OTHER PROVISIONS

Article 10

(Disciplinary action and personal liability)

1. A breach by any staff member of the provisions set forth in this Code constitutes a disciplinary offense and is subject to the rules set forth in this Article, and may result in contractual, administrative and / or criminal liability.

2. A breach by any staff member of the provisions of this Code shall be punished under the law, taking into account the severity of the breach, the degree of culpability of the offender and the consequences of the act, by applying a disciplinary sanction.

3. The Board of Directors shall decide regarding breaches of this Code by staff members.

Article 11

(Publication and disclosure)

This Code shall be published and made available on the Company’s website, and made known to all staff members.

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